Topic: Safety Deposit Boxes
-
We qualify for the alternative delivery method for our annual privacy notices. How should we notify CD and loan customers about the availability of the privacy notice, since we do not send those customers periodic statements or coupon books?
—
by
For any customers who do not receive periodic statements or other notices from your institution at least annually, you must provide a full annual privacy notice once per year — you cannot rely on the alternative delivery method for those customers. The alternative delivery method requirements include a requirement to provide a “notice of availability”…
-
We want to move safe deposit boxes to another branch due to a particular branch closing. We will move the boxes without opening them and we will send a certified notice that will explain the new location. Do you see any issues with this process?
—
by
No, we are not aware of any specific requirements that would apply to moving safe deposit boxes to another location. We recommend checking your account agreements to ensure that you have complied with any and all notification requirements.
-
Do we need to retain our dormancy letters and safe deposit box contracts? Can we store these records electronically?
—
by
Disclaimer: The Electronic Commerce Security Act (ECSA) was repealed and replaced with the Uniform Electronic Transaction Act (UETA), effective June 25, 2021. Please note that this change may affect the continued accuracy of this guidance as it pertains to the ECSA. Safe deposit box contracts. We are not aware of any specific legal requirements that apply…
-
If a safety deposit box has two living co-lessees, can a person holding a Power of Attorney for one lessee have the box drilled and closed out when the keys have been lost?
—
by
You should check the co-lessee’s power of attorney (POA) to determine whether it includes the power over “safe deposit box transactions.” The Illinois Statutory Short Form Power of Attorney for Property does include authority over safe deposit boxes in line item (e). 755 ILCS 45/3-3. When inspecting the co-lessee’s POA, you should ensure that this line…